LOTO 10 IMPORTANT PROCEDURAL DANGERS THAT ARE AVOIDABLE

Herbert Post March 20, 2020 4 min read

It's essential to have a lockout and safety tag system in place to protect the safety of the employees, but what are some of the common problems businesses encounter with their tagout systems?

It doesn’t matter what industry you look at; everyone has horror stories and near-miss stories about tagout procedures failing or almost failing. Despite our best efforts, the best training, effective procedures, and safety equipment, sometimes accidents happen.

Over the last thirty years, businesses across the United States have come a long way in improving their lockout/tagout procedures and equipment. This could be because of an increase of awareness surrounding lockout/tagout or because more businesses are complying with OSHA standard 29 CFR 1910.147.

The OSHA estimated that the lockout/tagout standard could prevent more than 100 fatalities and thousands of non‐fatal injuries every year. Below we’re going to take a look at ten of the most common problems with lockout/tagout procedures.

 

 

THE 10 MOST COMMON PROBLEMS WITH LOCKOUT AND TAG PROCEDURES:

1. Lack of adequate tagout/lockout procedures

You need to consider that machines and equipment are all different and may require different tagout lockout procedures. Having a blanket tagout/lockout procedure is great, but if it doesn’t apply to all of your machinery, then there could be gaps in the procedure. Under the OSHA requirements, a specific written procedure is required when a single lockout device will not achieve zero energy state.

2. Failure to train all employees

Most companies focus on training their employees that deal directly with the equipment, those applying locks and tags known as ‘authorized employees’ and also the operators of equipment known as ‘affected employees’, but did you know there’s also a third category that also requires training? This group is classified as ‘all other employees’ and also needs to be aware of lockout/tagout procedures. Even though they aren’t going to be operating or working on equipment, if they are in the general location of equipment, they still need to be trained.

3. Incorrect use of tags and locks

Unfortunately, sometimes danger tags or lockout tags are used as general information or warning tags. All ‘danger do not operate’ should only be used for the purpose intended otherwise;, it can degrade the seriousness and importance of the tag. If you need alternative tags, then they should be implemented separately to the lockout/tagout tags.

4. Incorrect use of locks

Lockout tags should never be used to lock tool boxes, lockers, cabinets, cages, or for any other purpose other than what they are intended for. As with the tags above, any use other than their intended use could degrade the importance of lockout locks.

5. Working under other people’s locks and tags

It is OSHA standard and best practice for employees that are working on equipment to apply their locks and tags. There is some allowance under OSHA Instruction STD 1-7.3 for sign in and sign out instead of using personal locks. If you allow one employee to be responsible for applying lockout locks and tags, then it opens up more opportunities for errors or mistakes to be made.

6. Failing to identify all energy sources

All energy sources need to be identified when applying locks and tags. If you fail to identify alternative activation or control points, then equipment isolations won’t be 100%. This is where the importance of individual machinery lockout/tagout procedures become more apparent.

7. Lack of annual reviews and audits of procedures

OSHA requires that annual audits and reviews be conducted of lockout/tagout procedures. This is to ensure that not only are procedures effective but also that employees understand and are following the procedures correctly. Audits and reviews can help to identify any problems or issues with procedures before an accident occurs.

8. Minor routine maintenance and changes compared to servicing maintenance

If it’s only something minor like a quick clean or changing a blade, are your employees following the lockout/tagout procedures, or are they taking shortcuts? Everyone must understand that the risks are the same regardless of whether or not it’s just a ‘five-minute’ job or five-hour shutdown.

9. Never assume that everything is okay

Just because you’ve never had any lockout/tagout accidents, it doesn’t mean that you’re not going to. Assuming that everything is going great just because there have been no accidents, doesn’t mean that it is. Audits and reviews of policy and procedures is an effective way to ensure that everyone is on the same page regarding lockout/tagout.

10. Duplicate keys

While duplicate keys may make it easier to remove a lock when an employee has incorrectly left it in place and left the premises, it also lessens the severity of cutting a lock off. Break out the bolt cutters and destroy that lock for good!

CONCLUSION

An effective lockout/tagout system is essential for all businesses and ensuring that your procedures are working correctly, and employees are following them is one of the biggest factors that businesses fail to act on. Annual audits and reviews are the most effective way to ensure that the lockout/tagout systems you have in place are adequate and working at 100%.

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Author: Herbert Post

VP Global Compliance at Barron Short Companies LTD. Born in the Philadelphia area and raised in Houston in a family who was predominately employed in heavy manufacturing. Herb took a liking to factory processes and later safety compliance where he has spent the last 13 years facilitating best practices and teaching updated regulations


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